Defence wording check please

pencilcaseblue

Thankyou for all the advice I've already read through! 
I had a PCN for stopping in a no-stopping zone in 2022. I completely ignored it as I did not stop, I took a wrong turn off a roundabout while trying to find a prebooked carpark. They provided a picture of my car in front of a barrier (not alongside double red lines which ended before the barrier). Upon realising I was at the wrong carpark I immediately left and drove to the correct carpark (I have confirmation of this other carpark and google location data). This happened at John Lennon airport.

Anyway, can I check I've done my defence letter correctly please?

2. The facts in this defence come from the Defendant's own knowledge and honest belief.  Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised and it is admitted that the Defendant was the registered keeper and driver.

3. The car did not stop in a “Red Route Stopping Control” (as defined by the The Highway Code published 1st October 2015) and no evidence has been provided showing any such breach.

After taking a wrong turn from the roundabout whilst in search for another (pre-booked) car park, there was nowhere to stop to determine which car park entrance was being approached (due to double red lines) and no provision to stop and read the terms and conditions which were not in prominent locations as per the claimants statement therefore a contract cannot be entered.

Upon realising that the driver was not at the pre-booked car park the car immediately exited by the shortest means possible. No person entered or exited the vehicle, no luggage was left or collected. 

The rest of the letter (apart from the header and signature) I've copy and pasted EXACTLY as the newbies sticky post. I've not mentioned evidence or witnesses. I've tried to keep it in the 3rd person.
Many thanks.

Coupon-mad

Welcome!

There are lots of VCS Airport defences being discussed this week, including the one where someone has just finalised a far stronger defence re Bristol Airport.

No link. It was today, Go find it!

Show us the POC with the usual 4 things redacted, as you saw in all the other threads.  Any VCS Airport threads are worth you reading. Doesn't matter which Airport.